Jeffrey Korenblatt

Partner Norton Rose Fulbright US LLP
Jeffrey Korenblatt

Jeffrey Korenblatt

Biography

Jeff Korenblatt is a tax lawyer with more than two decades of experience advising on a variety of complex domestic and cross-border business transactions. A key part of his practice is advising insurance companies, managing general underwriters and managing general agents with respect to evaluating and underwriting sophisticated, high-value tax risks tied to issues such as renewable energy credit qualification, credit transfers under Section 6418 of the Internal Revenue Code, net operating loss availability, complex leasing transactions, domestic and cross-border M&A and financing transactions, planning involving employee benefits plans and executive compensation, state tax matters, US effectively connected income exposures and debt versus equity risk, among other issues.

His broader practice includes advising US and foreign taxpayers on the full lifecycle of domestic and cross-border M&A tax planning. This includes advising on the efficient implementation of both taxable and tax-free reorganizations, combinations and spinoffs. He is also experienced in structuring joint ventures and providing guidance regarding S corporate and partnership formations, acquisitions, restructurings and divestitures. Jeff has detailed knowledge relating to the navigation of the US anti-deferral rules, such as subpart F and GILTI, transfer pricing rules and methodologies and international tax treaties. 

Jeff frequently advises clients on the formation and operation of private investment vehicles and on the tax considerations important to their investors, general partners and advisers. He has years of experience helping clients navigate the special tax and transfer pricing considerations of multijurisdictional business ventures, combinations and expansions.

Professional experience

Representative experience

Representative experience

  • Advised multiple insurance companies, managing general underwriters and managing general agents in connection with underwriting diverse tax risks, including risks related to:
    • Corporate acquisitions, dispositions, restructurings and cross-border redomiciliations
    • Inbound investment structures and cross-border withholding challenges
    • US tax rules applicable to outbound investment, including tax credits and the US anti-deferral tax rules
    • Debt-vs-equity characterization and sale-vs-lease transactions
    • Complex tax accounting
    • S corporations, partnerships and closely held business structures
    • Employee benefits and executive compensation
    • The intersection of specific US and non-US tax matters in multiple jurisdictions
    • State tax issues
  • Assisted diverse tax insurance industry clients with evaluating and underwriting risks associated with various renewable energy projects, including transactions involving section 45 production tax credits, section 48 investment tax credits, other renewable energy incentives and the sales of the associated credits under section 6418.
  • Guided both buyers and sellers with tax-efficient purchases and sales of the equity and/or assets of domestic or international businesses.
  • Provided cutting-edge and proactive transfer pricing advice, particularly for IP, financing transactions, the procurement and distribution of goods and the performance of services.
  • Designed and implemented pre- and post-acquisition/disposition business integration and rationalization strategies.
  • Structured varied business franchising arrangements in more than 35 jurisdictions worldwide for US and foreign taxpayers.
  • Advised foreign persons on establishing or acquiring US business operations.
  • Advised domestic and foreign investors in US and foreign real estate and energy properties, including through structures compliant with Islamic banking and finance requirements.
  • Provided complex tax advice on offerings of debt, equity and other financial instruments, as well as with respect to lending transactions and recapitalizations.
  • Developed and optimized cross-border procurement, supply chain and distribution structures.
  • Advised multiple clients on the use of specialized capital markets structures, such as the use of "Up-C" and special purpose acquisition companies (SPACs).
  • Represented US and foreign clients in multiple aspects of the token and cryptocurrency economy.
  • Advised on the tax-efficient creation, financing, acquisition, ownership, exploitation and disposition of film, music and derivative rights throughout the US and worldwide.

Rankings and recognitions

Rankings and recognitions

  • Legal 500 US, Recommended lawyer, Tax, The Legal 500, 2019-2021

Education

Education

  • JD, University of Michigan School of Law, 1997
  • BS, cum laude, Georgetown University, 1992

Admissions

Admissions

  • District of Columbia Bar

Speaking engagements

Speaking engagements

  • Co-presenter, “Managing Tax Liabilities in Corporate Transactions,” Practicing Law Institute: Understanding & Deploying Tax Insurance, October 25, 2024
  • Co-presenter, “Bridging Comfort Levels with Tax Insurance,” Southern Federal Tax institute, October 23, 2024
  • Panelist, “Tax Insurance in Cross-Border M&A Transactions,” Third Annual Tax Liability Insurance ExecuSummit, October 8, 2024
  • Co-presenter, “Managing Tax Liabilities in Corporate Transactions,” Practicing Law Institute Reps & Warranties and Transactional Risk Insurance, October 5, 2023
  • Speaker, “Tax Treaties,” Annual Institute on Current Issues in International Taxation, George Washington University School of Law/IRS (GW/IRS) Institute, December 14, 2023
  • Panelist, “Managing Tax Liabilities in Corporate Transactions, Reps & Warranties and Transactional Risk Insurance 2023,” ExecuSummit, October 5, 2023
  • Speaker, “International Tax Developments (Outbound),” Federal Bar Association Tax Law Conference, March 5, 2021
  • Lecturer, “Overview of US International Tax Rules,” International Bureau of Fiscal Documentation, April 25, 2018
  • Speaker, “IP Planning After Reform: Offshore or Onshore?” Tax Executives Institute 68th Midyear Conference, March 26, 2018
  • Speaker, “International Tax Developments,” Federal Bar Association Tax Law Conference, March 9, 2018
  • Speaker, “Foreign Currency Developments, Including Guidance Under Section 987,” Federal Bar Association Tax Law Conference, March 3, 2017

Memberships and activities

Memberships and activities

  • Federal Bar Association, International Tax Program, Tax Law Conferences, Co-Chair, 2014-2021
  • Adjunct professor in the L.L.M. degree program (US Outbound International Taxation), Georgetown University Law Center, 2017-2019
  • American Bar Association, Committee of Foreign Activities of US Taxpayers
  • International Bar Association

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